Zvi Halpern-Shavim
Partner | Toronto
Toronto: 416-863-2355

Zvi's practice involves all areas of commodity tax, with a focus on planning and advising clients in connection with goods and services tax, harmonized sales tax, provincial sales tax, insurance premium tax, excise taxes and duties, customs valuation, tariff classification, import/export restrictions, and various aspects of the North American Free Trade Agreement and Canada's other bilateral trade agreements. Zvi provides compliance, planning, audit and tax dispute expertise, both in traditional M&A and real property transactions and in complex and new areas of financial services, natural resources, cross-border, the sharing economy, P3 infrastructure projects, cryptocurrencies, medical, pharmaceutical and agribusiness.

SELECT EXPERIENCE

Recent representative matters include advising:

Financial Services

  • Standard Life plc on the sale of its Canadian business to Manulife for C$4-billion

  • Canadian Tire Corporation, Limited on the sale to Scotiabank of a 20 per cent interest in its financial services business for C$500-million

  • The Toronto-Dominion Bank on its acquisition of artificial intelligence firm Layer 6 Inc.

Real Property

  • JCF Capital ULC in connection with its acquisition of the former Trump Tower, Toronto, a mixed hotel/residential condominium, and the sale of the hotel portion to InnVest Hotels
  • BluEarth Renewables Inc. in relation to the acquisition, construction, operation and maintenance of various solar and wind power projects
Medical/ Pharmaceutical

  • A private equity firm in connection with its acquisition and continuing consolidation of specialist dental and orthodontist practices across Canada
Infrastructure

  • Various P3 Project Cos and Project Owners in connection with GST/HST in contractual negotiations, assessments and refunds for public infrastructure and similar projects
AWARDS & RECOGNITION

Zvi is recognized as a leading lawyer in International Tax Review's Indirect Tax Leaders 2015-2018 (currently 7th Edition).

PUBLICATIONS
Show Past:
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Author: Unresolved Issues for Cannabis Excise Duties Policy
Options Magazine, September 5, 2018.
Co-author: Place of Delivery: A Deceptively Complex GST/HST Problem
Sales Tax, Customs & Trade Journal, Federated Press, Vol. XV, No. 2, July 2018.
Blakes Bulletin on The Sharing Economy, June 12, 2018.
Canadian Tax Focus, Canadian Tax Foundation, May 2018.
Co-author: Canada: Federal Court authorises CRA to obtain taxpayer information directly from PayPal Canada
International Tax Review, April 2018.
Blakes Bulletin on Cannabis, March 8, 2018.
Blakes Bulletin on Cannabis, March 2, 2018.
Co-author: Chapter 11 - Canada
International Comparative Legal Guide to: Corporate Tax, Global Legal Group, 2018.
Co-author: Bracing Changes: Tax Court Takes a Bite Out of ITC Claims by Orthodontists
Sales Tax, Customs & Trade Journal, Federated Press, Vol. XIV, No. 3, 2017.
Co-author: Searching for a Pot of Gold: Taxing Marijuana in Canada
Sales Tax, Customs & Trade Journal, Federated Press, Vol. XIV, No. 1, 2017.
Co-author: Finance Canada Seeks Comments on New Tax Proposals Regarding Investment Limited Partnership Rules
Canadian Current Tax, Vol. 28, No. 1, October 2017.
Co-author: Indirect Taxes, Canada: Cross-Border Developments
The Professional Journal of Tax Executives Institute, Vol. 69, No. 4, July/August 2017.
Canadian Tax Focus, Canadian Tax Foundation, February 2017.
Conference Report 2016, Report of Proceedings of the Sixty-Eighth Tax Conference, Ch. 35, pp. 1-26, Canadian Tax Foundation, 2017.
Co-author: Court Rejects ITCs for Corporation as "Personal Expenses" After Business has Wound Down
Sales Tax, Customs & Trade Journal, Federated Press, Volume XII No. 2 2016.
Co-author: Five Arbitrary Differences Between Corporations and Partnerships for GST/HST Purposes
Sales and Use Tax, Volume XIII, No. 2, Federated Press, November 2015.
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PROFESSIONAL APPEARANCES
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Speaker: Tax Executives Institute Dallas Chapter
Annual Canada Tax Luncheon, Dallas, Texas, April 17, 2018.
Co-presenter: Income and Commodity Tax Considerations for the Sharing Economy
68th Annual Tax Conference, Calgary, Alberta, November 28, 2016.
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